In our examination of two recent OCC BSA/AML consent orders, one with a bank and another with an individual in-house professional, we review the OCC’s allegations underlying the orders and how the OCC focuses on the core pillars of BSA/AML compliance when choosing to pursue enforcement. We also discuss the takeaways for boards and management of financial institutions when accepting higher-risk customers, including digital currency exchanges, and what the AML liability risk is for individuals – including how such risk can be minimized, and the inherent tension between the interests of institutions and their executives and compliance officers. Finally, we discuss how the use of third-party consultants and advisors regarding AML compliance can be a double-edged sword for financial institutions and individuals facing downstream enforcement actions.

Click here to listen to the podcast. For more information on BSA/AML compliance, visit Money Laundering Watch, a blog on which members of Ballard Spahr’s White Collar Defense/Internal Investigations Group regularly report on BSA/AML developments.

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ABOUT THE CFS GROUP

The Consumer Financial Services Group is nationally recognized for its guidance in structuring and documenting new consumer financial services products, its experience with the full range of federal and state consumer credit laws throughout the country, and its skill in litigation defense and avoidance, including pioneering work in pre-dispute arbitration programs.
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